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Full text of "Kansas City Maintenance Area 8-Hour Maintenance Plan for the Control of Ozone 2007"

State of Missouri 
The Kansas City Maintenance Area 
8-Hour Maintenance Plan 
for the Control of Ozone 



Missouri Air Conservation Commission 
Adopted: April 26, 2007 



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Department of Natural Resources 
Division of Environmental Quality 
Air Pollution Control Program 
P.O. Box 176 
1659 East Elm Street 
Jefferson City, Missouri 65102 
Telephone (573) 751-4817 



ACKNOWLEDGMENTS 



The information analysis and documentation contained in this plan represents 
the cooperative efforts of many agencies. The Missouri Department of 
Natural Resources' Air Pollution Control Program gratefully acknowledges 
participants from the following agencies: 



Kansas Department of Health and the Environment 
U.S. Environmental Protection Agency - Region VII 
Mid America Regional Council - Air Quality Forum 



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TABLE of CONTENTS 
EXECUTIVE SUMMARY 5 

1.0 BACKGROUND / INTRODUCTION 7 

1 . 1 National Ambient Air Quality Standard for Ozone 7 

1.2 Ozone and Its Formation 9 

1.3 Negative Effects of Ozone 10 

1.4 Geographical Description of the Kansas City Maintenance Area 10 

1.5 Kansas City Ozone History 10 

1.5.1 One Hour Ozone Designation 11 

1.5.1.1. 1979 Ozone Implementation Plan History 11 

1.5.1.2. 1987 Ozone Implementation Plan 11 

1.5.1.3. 1997 Maintenance Plan History 12 

1.5.1.4. 2002 Maintenance Plan History 15 

1.5.2 8-Hour Ozone Designation 18 

1.6 Current Ozone Maintenance and Contingency Planning 20 

2.0 REQUIREMENTS 20 

2. 1 Clean Air Act Requirements 21 

2.2 Administrative Requirements 22 

2.2.1 Legal Authority 22 

2.2.2 Public Hearing Notice and Certification 23 

2.2.3 Comments, Responses, and Explanations of Change 23 

2.2.4 MAC C Adoption Certification 23 

2.2.5 Commitment to Revise Plan 23 

3.0 CONTROL MEASURES 23 

3.1 Current Control Measures 23 

3.1.1 Federal Control Measures 24 

3.1.2 State Control Measures 25 

3.2 Voluntary Control Measures 25 

3.2.1 Clean Air Action Plan 25 

3.2.1.1 Modeling 26 

3.2.1.2 Approval and Submission of CAAP 27 

3.2.1.3 CAAP Measures Implemented 27 

4.0 MONITORING NETWORK 27 

4. 1 Ozone Monitoring Network 27 

4.2 Ambient Air Monitoring 28 

4.3 Monitoring Based Attainment Demonstration - Design Values for the KCMA.. 29 

4.4 Missing Data Under the Eight-Hour Ozone Standard 29 

4.5 Quality Assurance Program 30 

4.6 Continued Ambient Air Monitoring 30 

5.0 EMISSIONS INVENTORY 31 



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5 . 1 Attainment and Projected Inventory 31 

5.2 Anthropogenic Emissions 33 

5.2.1 Point Source Emissions 33 

5.2.1.1 Point Source Emission Description 33 

5.2.1.2 Point Source Emissions Projection Year Calculation 34 

5.2.2 Area Source Emissions 35 

5.2.2.1 Area Source Emissions Description 35 

5.2.2.2 Area Source Projection Year Calculation 37 

5.2.3 Onroad Mobile Source Emissions 38 

5.2.3.1 Onroad Mobile Source Emissions Description 38 

5.2.3.2 Onroad Mobile Source Emissions Calculation 38 

5.2.4 Offroad Mobile Source Emissions 39 

5.2.4.1 Offroad Mobile Source Emissions Description 39 

5.2.4.2 Offroad Mobile Source Emissions Calculations 39 

5.3 Biogenic Emissions 40 

5.3.1 Biogenic Emissions Description 40 

5.3.2 Biogenic Emissions Calculations 41 

5.4 Maintenance Demonstration 41 

5.5 Verification of Continued Attainment 41 

6.0 CONTINGENCY PLANNING 42 

6. 1 Purpose of Contingency Planning 42 

6.2 Contingency Measures 43 

7.0 CONFORMITY 45 

7.1 Purpose of Conformity 46 

7.2 Conformity Requirement 46 

8.0 REFERENCE INFORMATION 47 

8.1 List of References 47 

8.2 List of Acronyms and Abbreviations 48 

8.3 List of Appendices 50 



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EXECUTIVE SUMMARY 

The Kansas City Maintenance Area (KCMA) is designated as an attainment area for the 
8-hour ozone standard and as a maintenance area under the previous one-hour ozone standard. 
Based on these designations, the KCMA is required to have a maintenance plan under section 
1 10(a)(1) of the Clean Air Act (CAA) and the provisions of the U.S. Environmental Protection 
Agency (EPA)'s Phase 1 Implementation Rule for the 8-hour Ozone Standard (40 Code of 
Federal Regulations (CFR) Section 51.905(a)(3) and (4)). The Missouri Department of Natural 
Resources' Air Pollution Control Program has prepared this maintenance plan to meet all of the 
requirements for the 8-hour ozone standard for its portion of the KCMA. The Missouri portion 
of the KCMA is based on designations determined under the previous one-hour standard, and is 
made up of Clay, Platte, and Jackson counties. 

The maintenance plan includes all of the components required under the CAA and EPA's 
Phase I Rule. This 8-hour ozone maintenance plan constitutes a revision to the State 
Implementation Plan and must provide for continued maintenance of the 8-hour ozone standard 
for a period of 10 years, ending in 2014. The plan must also provide contingency control 
measures to be implemented if a violation of the 8-hour ozone standard occurs. These control 
measures must be able to meet the EPA's desired timeline for adoption and implementation of 
control measures, which is defined as expeditious as practicable, but no longer than 24 months. 

Guidance from the EPA for the development of the maintenance plan also recommends 
that the plan include a number of additional elements. One of these recommendations is an 
attainment inventory of typical ozone season (summer) day emissions for a base year. The base 
year for this emissions inventory of volatile organic compounds, nitrogen oxides and carbon 
monoxide was developed for a typical summer day in 2002. The attainment emissions inventory 
was then projected forward to determine the emissions levels in the attainment year of 2014. 

The EPA's guidance also recommended that two other elements be included in the 
maintenance plan. One of these elements is agreement from the state of Missouri to continue 
operating an air quality monitoring network in the KCMA to verify maintenance of the 8-hour 
ozone standard in the area. The department' s Air Pollution Control Program fully intends to 
continue monitoring the air quality on the Missouri side of the KCMA. As in the past, any 
modifications made to the monitoring network will be done through close consultation with the 
EPA regional office. The final element suggested by the EPA's guidance is the inclusion of a 



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procedure to monitor the progress of the maintenance plan. It is the intention of the department's 
Air Pollution Control Program to periodically update the emissions inventory throughout the life 
of the maintenance plan. It is anticipated that these updates will occur approximately every three 
years until the attainment year of 2014. 

Based on the emissions projections developed for this maintenance plan, it is anticipated 
that the area will remain in attainment for the 8-hour ozone standard throughout the life of the 
plan. In fact, when the emissions for the base year of 2002 are compared with the projected 
emissions for 2014, emissions for the KCMA are expected to decrease. However, there are 
many factors that affect the formation of ozone, not just the projected growth or decrease of 
emissions for an area. Therefore, the department's Air Pollution Control Program commits to 
the implementation of contingency measures in the Missouri portion of the KCMA if a violation 
of the 8-hour ozone standard occurs. 

The contingency control measures have been designed as a two phased approach with 
implementation occurring when the trigger of a specific phase occurs. Phase I will be triggered 
by a violation of the ozone standard. Phase I would result in specific control measures being 
enacted. Phase II would be triggered after Phase I control measures had been given sufficient 
time to impact the air quality in the KCMA. Phase II provides a list of emission control measure 
options that would go through further review. It is the intention of the department's Air 
Pollution Control Program that selected measures would be enacted based on their emission 
reduction benefits, cost effectiveness, and timeframe of implementation. 



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1.0 BACKGROUND / INTRODUCTION 



1.1 National Ambient Air Quality Standard for Ozone 

Congress first enacted the Clean Air Act (CAA) in 1970. It was last amended in 1990. 
The CAA requires the U.S. Environmental Protection Agency (EPA) to set National Ambient 
Air Quality Standards (NAAQS) for pollutants considered harmful to public health and the 
environment. There are two categories of NAAQS that are set by the EPA. The primary 
standards are health-based standards and are designed to establish limits to protect public health. 
The secondary standards are commonly referred to as "welfare -based standards" and they are 
meant to set limits to protect public welfare. These limits are intended to protect against 
decreased visibility, and damage to crops, animals, and buildings. Currently there are six 
pollutants with established primary level NAAQS. These pollutants are carbon monoxide, lead, 
total suspended particles, sulfur dioxide, nitrogen oxide, and ozone. These pollutants are 
referred to as "criteria" pollutants. The EPA establishes a standard for each criteria pollutant. If 
an area is found to exceed this value, it is classified as a nonattainment area for that specific 
pollutant. The states and/or tribes responsible for the affected area must then develop and carry 
out strategies and measures to attain the NAAQS. The goal is for any areas designated as 
"nonattainment" to be reclassified by the EPA to attainment for the pollutant. 

In 1971, the EPA established a standard for photochemical oxidants. In 1979, the EPA 
changed the photochemical standard to a national ozone standard of 0.12 parts per million (ppm) 
of ozone in ambient air, based on a one-hour averaging period. According to the standard, a 
single monitor was allowed to experience an average of one exceedance of the standard per year 
over a three-year period. Exceedances of the standard are determined on a per monitor basis. 
The fourth exceedance for a specific monitor in a three-year time period would result in a 
violation of the one-hour standard. Due to the EPA's rounding conventions, an area had to have 
a one-hour ozone concentration of 0.125 ppm at a monitor to be in violation of the standard, and 
to potentially be declared a nonattainment area. 

The CAA requires that the EPA carry out a periodic review of NAAQS for the criteria 
pollutants. This review must include the scientific basis for (1) changing or reaffirming the 



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NAAQS and (2) implementing the NAAQS. As required by the CAA, the EPA reviewed the 
one-hour NAAQS for ozone in the 1990' s and determined that a new standard was needed. This 
new standard was finalized in July of 1997. The replacement of the ozone NAAQS was done 
under subpart 1 of the CAA, Title I, Part D. 

The new ozone standard is based on an eight-hour averaging period. This standard 
defines an area as in attainment of the 8-hour ozone standard when the three-year average of the 
annual fourth highest daily maximum 8-hour ozone concentration is less than or equal to 0.08 
ppm (or 80 parts per billion (ppb)). Due to rounding conventions in the new standard, an 8-hour 
average ozone concentration above 0.085 ppm is considered an exceedance of standard. When 
the three-year average value is 0.085 ppm or greater, a violation of the ozone NAAQS has 
occurred. As with the previous one-hour standard, a violation of the eight-hour standard is 
determined on a per monitor basis. Monitor readings (and exceedances) at one location do not 
have any affect on the readings at another. 

The EPA was challenged in court on the new 8-hour standard, and the one-hour standard 
was reinstated. The Supreme Court upheld the constitutionality of 8-hour standard, but ruled that 
the EPA could not implement the new standard under subpart 1 of the CAA without considering 
the CAA's subpart 2 requirements. Subpart 2 specifies area classification for nonattainment 
areas with additional control strategy requirements for each classification. The Supreme Court 
left it to the EPA to develop a reasonable resolution of the roles of subparts 1 and 2 in 
implementing a revised ozone standard. The rule was remanded back to the EPA in order to 
develop a reasonable approach to implement the new standard while considering the roles of 
subparts 1 and 2 in the implementation. 

On March 18, 2002, the EPA published a Notice of Public Meeting in the Federal 
Register regarding the implementation of the 8-hour ozone standard to address subpart 2 of the 
requirements per the Supreme Court decision. On March 26, 2002 the U.S. Court of Appeals for 
the District of Columbia unanimously rejected all remaining challenges to the EPA's new ozone 
and fine particulate standards. On June 2, 2003, the EPA published the Proposed Rule to 
implement the 8-Hour Ozone National Ambient Air Quality Standard in the Federal Register. 
Phase 1 of the Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality 
Standard was released on April 30, 2004. This rule provided the guidance to develop the 



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maintenance plan for areas that were in attainment for the 8-hour standard, but had previously 
been in nonattainment for the one-hour standard. 

On December 22, 2006, the U.S Court of Appeals for the District of Columbia handed 
down a decision that may impact the 8-hour ozone standard. At this time, the state of Missouri 
has determined that the best course of action is to follow the timeline established by Phase 1 of 
the Final Rule. The ultimate outcome of this court case may affect this Maintenance Plan, and 
require a revision after the EPA submittal deadline for this plan. 

1.2 Ozone and Its Formation 

Ozone is a reactive chemical compound. It is made up of three oxygen atoms and is 
identified by the chemical symbol O3. Ozone is a gas that occurs both in the Earth's upper 
atmosphere and at ground level. Depending on where ozone is found, it can be good or bad. 
When it occurs naturally in the upper atmosphere, ozone acts as a shield from the sun's harmful 
ultraviolet rays. However, ground-level ozone is a concern during the summer months when the 
weather conditions are favorable for producing ozone. 

Unlike most other pollutants, ozone is not emitted directly into the air by specific sources, 
but is formed by a photochemical reaction. This reaction occurs between oxides of nitrogen 
(NOx) and volatile organic compounds (VOCs) in the presence of sunlight and elevated ambient 
temperatures. There are numerous sources of NOx and VOC pollutants. These sources are 
divided into four types, including stationary, area, mobile and natural. Stationary sources 
include larger permitted industries and power plants. Area sources are small, stationary, non- 
transportation sources that collectively contribute to air pollution. Examples of area sources 
include gas stations, automotive shops and dry cleaners. Mobile sources are divided into two 
categories: on-road and off-road. On-road mobile sources include cars, trucks and buses. Off- 
road sources include trains, ships, boats, airplanes, lawn equipment, and construction equipment. 
Natural sources for VOCs are released from vegetation, such as trees. Natural NOx sources are 
very rare, but include lightening and soil. Ozone is most commonly an urban air issue, but high 
ozone readings can also be found in rural areas. This is due to the fact that emissions of NOx 
and VOC from motor vehicles and stationary sources can be carried hundred of miles from their 
origins, and contribute to high ozone concentrations over very large, multi- state regions. 



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1.3 Negative Effects of Ozone 

Ozone is a strong oxidizing agent, with the potential to damage or impair lung airways 
and cause inflammation. People with respiratory problems are the most vulnerable to its effects, 
but even healthy people that are active outdoors can be affected when ozone levels are high. 
Relatively low amounts of ozone can cause chest pain, shortness of breath, and coughing. Ozone 
can also worsen asthma, bronchitis, and emphysema. Repeated exposure to ozone pollution for 
several months may cause permanent lung damage. Anyone who spends time outdoors in the 
summer is at risk, particularly children and active adults. 

Ground level ozone can also have negative effects on plants and other vegetation by 
interfering with their ability to produce and store food. It can also reduce agricultural 
productivity and forest yields. Ozone also affects manufactured products. It causes or 
accelerates the deterioration of building materials, surface coatings, rubber, plastic products and 
textiles. 

1.4 Geographical Description of the Kansas City Maintenance Area 

The Kansas City Maintenance Area (KCMA) consists of five (5) counties within the 
larger bi-state Kansas City Metropolitan Statistical Area (MSA). The counties included in the 
KCMA were determined by violations of the now revoked one-hour ozone standard, and will 
continue to be monitored for the 8-hour ozone standard. These counties include Jackson, Clay 
and Platte counties in Missouri, and Johnson and Wyandotte counties in Kansas. The Kansas 
Department of Health and Environment (KDHE) is developing a similar implementation plan for 
the Kansas counties in the KCMA. A map of the area can be found in Appendix A. 

1.5 Kansas City Ozone History 



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1.5.1 One Hour Ozone Designation 

1.5.1.1. 1979 Ozone Implementation Plan History 

In the 1970' s, the Kansas City Area was determined to be in violation of the one-hour 
ozone NAAQS. The CAA requires any area that fails to attain the standard for a criteria 
pollutant (such as ozone) to develop and implement a State Implementation Plan (SIP) with 
sufficient control requirements to expeditiously return the area to attainment status. In 
compliance with federal law, the state of Missouri developed and implemented its first Kansas 
City Ozone Implementation Plan in 1979. 

The 1979 plan projected attainment of the ozone NAAQS for the KCMA by December 
31, 1982. The EPA fully approved the 1979 Kansas City Ozone Implementation Plan, and the 
area appeared to meet the standard at that time. However, violations in the 1983 and 1984 ozone 
seasons required the state to review the 1979 ozone plan. 

1.5.1.2. 1987 Ozone Implementation Plan 

The revisions to the 1979 version of the Plan were included as part of the 1987 Ozone 
Implementation Plan. The 1987 SIP submittal also incorporated all of the requirements under 
the EPA's post-1982 nonattainment policy. The 1987 Ozone Implementation Plan projected 
attainment of the ozone standard by December 31, 1987. On November 2, 1989, the EPA fully 
approved the 1987 Ozone Implementation Plan, making the control measures contained in the 
plan federally enforceable. 

Ozone monitoring data for the ozone seasons of 1985 through 1987 again indicated that 
the one-hour ozone standard had been achieved in the KCMA. Thus, work was initiated on 
maintenance provisions to the Missouri SIP, as well as an attainment redesignation request to the 
EPA for the area. However, violations in the monitoring period from 1986 through 1988 caused 
the KCMA to again be in violation of the ozone standard. 

Ozone monitoring data for the monitoring period from 1987 through 1991 demonstrated 
that the area had again attained the one-hour standard. In accordance with the Clean Air Act 
Amendments of 1990 (CAAA), the 1991 Kansas City Maintenance Plan was developed to 
recognize that the area had achieved the one-hour ozone standard. The EPA published final 
approval of this maintenance plan on June 23, 1992. This final approval allowed the 1991 plan 



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to become effective on the same day. The EPA's approval officially re-designated the KCMA to 
attainment for the one hour standard. 

1.5.1.3. 1997 Maintenance Plan History 

In the summer of 1995, the KCMA experienced a period of severe hot weather. During 
this time, the KCMA recorded its fourth exceedance for the monitoring period of 1993-1995, 
which resulted in another violation of the one-hour standard. This violation mandated that the 
contingency control measures listed in the 1991 plan be adopted. These control measures 
included: 

• Emissions offsets of 1:1 for all major sources 

• Stage II Vapor Recovery, or Enhanced Inspection and Maintenance (I/M) 

• Transportation Control Measures (TCM) achieving a 0.5% reduction in area VOC 
emissions 

• A comprehensive emissions inventory 

The states of Missouri and Kansas, along with the Mid- America Regional Council 
(MARC), expressed to the EPA a need to amend the control measures listed in the contingency 
section of the 1991 plan. The EPA agreed that the contingency measures could be changed as 
long as the revised plan achieved the same level of control as intended by the original measures. 

The states asked the MARC Air Quality Forum (AQF) to aid in the review of the control 
measures available to the KCMA. The AQF convened the Ozone Subcommittee to conduct a 
technical analysis of a number of control measures. The Ozone Subcommittee evaluated the 
following measures: Reformulated Gasoline (RFG), Low Reid Vapor Pressure (RVP) Gasoline, 
Stage II Vapor Recovery, and 14 different I/M Programs. The Ozone Subcommittee also 
evaluated transportation control measures, including: 

• Increased bus service during the ozone season 

• Free transit during the ozone season 

• Free transit on red skycast days 

• Commuter rail along the Interstate 35 corridor 

• Light rail transit 

• Clean fuel fleets 

• Lanes for high occupancy vehicles 



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• Enhanced traffic signalization on arterial routes 

• Nontraditional work scheduling and commuting 

• Telecommuting 

• Parking surcharges 

• Taxes on vehicle miles traveled and/or gasoline 

The AQF reviewed the Ozone Subcommittee report and recommended the following control 
measures: 

• Expanded public education 

• Low RVP gasoline 

• Motor vehicle I/M 

• Seasonal no-fare transit 

• Clean fuel fleets 

The AQF also recommended enhanced traffic signalization, expanded mass transit, 
expansion of the Heartland Sky Program, improved land use planning, additional air quality data 
collection, expanded public education, and a stationary source study as supplementary measures. 

The AQF recommended that the states implement a low RVP fuel program requiring 7.2 
RVP gasoline in the KCMA. The Missouri Department of Natural Resources developed a 
regulation that limited the RVP of gasoline sold in the KCMA between June 1 and September 15 
to 7.2 pounds per square inch (psi). An emergency rulemaking was published on January 2, 
1997, which required all gasoline sold in the KCMA during the 1997 peak ozone season to be 
7.2 psi. The Missouri Air Conservation Commission (MACC) held a public hearing on May 29, 
1997, on the permanent RVP rule for the KCMA. The permanent rule was presented for 
adoption at the June 26, 1997 MACC meeting. The Commission adopted the rule as presented. 
The final rule was published in the September 3, 1997 Missouri Register. The Low RVP rule, 10 
CSR 10-2.330 Control of Gasoline Reid Vapor Pressure, became effective on October 30, 1997. 

In addition to these rules, the violation of the ozone standard required a revised 
maintenance plan to be submitted to the EPA. In addition to the low RVP gasoline rule, other 
measures such as: additional VOC emission reduction rules for stationary sources, increased 
ambient air monitoring, reduced transit fare on yellow and red skycast days, Clean Cities 



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programs, enhanced traffic signalization, and improved land use planning were committed to in 
the revised plan. The maintenance plan also included the AQF's long term recommendation of 
an I/M program. This plan was presented for public hearing at the April 24, 1997 MACC 
meeting. 

The plan was presented to the MACC for adoption on June 26, 1997 meeting. At that 
time, the Commission recommended that the department's Air Pollution Control Program revise 
the plan to replace the proposed I/M program with Stage II Vapor Recovery. The decision to 
replace the I/M program with Stage II Vapor recovery was based partially on the difficulty in 
implementing an I/M program in consideration of political feasibility and the time period that 
would be required to develop such a program. At the July 24, 1997 MACC meeting, MARC 
asked the Commission to allow the department to take the control plan back to the AQF for 
further review. The Commission granted this request, and gave the department until December 
of 1997 to present the revised plan at a public hearing. 

One September 3, 1997, the AQF met to review the recommendations of the 
Commission. The AQF also addressed a second violation of the ozone standard that occurred on 
August 28, 1997. During the meeting, control strategies were discussed including Stage II Vapor 
Recovery and RFG gasoline. The AQF convened on October 7, 1997 to recommend the control 
strategies for the KCMA. The forum recommended the implementation of an RFG program as 
well as the previously approved measures. The AQF recommended that Stage II Vapor 
Recovery be included as a contingency measure in the event that implementation of an RFG 
program was unsuccessful. 

The department's Air Pollution Control Program amended the revised maintenance plan 
to reflect the latest forum recommendations. It was decided that the Commission would 
determine the implementation year for the RFG program. The maintenance plan was drafted 
with the request for comments on the implementation date included. Also included in the plan 
was the commitment to implement Stage II Vapor Recovery if an RFG program could not be 
implemented. 

On February 3, 1998, the Commission adopted the revised Kansas City Ozone 
Maintenance Plan. The recommended implementation date for an RFG program was set as April 
15, 2000. The department's Air Pollution Control Program committed to making a formal 
request to the Governor of Missouri to include the Missouri counties of the KCMA into the 



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federal RFG program. This revised maintenance plan was sent to the EPA on March 25, 1988. 
EPA approved the plan on January 29, 1999. 

1.5.1.4. 2002 Maintenance Plan History 

As the maintenance plan required, the department' s Air Pollution Control Program 
updated the MACC on the status of the Federal RFG amendment at the August 1998 meeting. 
The department's Air Pollution Control Program recommended that the Commission delay any 
action until the September 24, 1998 MACC meeting, pending the EPA's decision on permitting 
the KCMA to join the RFG program. 

At the September 24, 1998 MACC meeting, the department's Air Pollution Control 
Program requested direction from the Commission on moving forward with the maintenance 
plan as adopted. The Commission was informed that the EPA was passing the needed 
regulations to allow former nonattainment areas such as those found in Missouri and Kansas to 
request RFG for the KCMA. On September 29, 1998, the EPA published the Federal opt-in rule 
amendment to allow former nonattainment areas such as the KCMA to opt-in to the Federal RFG 
program. The Commission agreed that the department's Air Pollution Control Program should 
move ahead with the maintenance plan as adopted. 

On April 6, 1999, the EPA disapproved the Long Range Transportation Plan (LRTP) for 
the KCMA. This disapproval was based on the lack of a formal commitment from the states to 
reduce the emissions in the KCMA. The Federal Highway Administration (FHA) stopped 
approving new roadway projects on May 7, 1999. The FHA set the initial date that highway 
funding would be withheld as July 28, 1999. 

On May 27, 1999, the EPA published its conditional approval of the submitted 
maintenance plan. The approval was based on one of the following three conditions being met: 
that the Governor of Missouri request to opt-in to the Federal RFG program; the state implement 
a regulation for a state fuel; or Stage II Vapor Recovery be implemented. One of these options 
had to be completely implemented by April 15, 2000. 

On June 2 and 3, 1999, the department's Air Pollution Control Program, in conjunction 
with KDHE, held a Kansas City Fuel Summit to discuss the implementation of the ozone 
maintenance plan options. Although the summit did not result in a clear recommendation to 



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pursue the Federal RFG program, it did illustrate the problems and difficulties in not pursuing 
the Federal RFG option. 

On July 27 and 28, 1999 Governor Graves of Kansas and Governor Carnahan of 
Missouri, respectively, signed letters requesting that the KCMA be included in the Federal RFG 
program. By submitting these opt-in letters to the EPA, the LRTP was brought back into 
conformity. This made the transportation plan appro vable and allowed for the continued 
distribution of highway funding for the KCMA. The submission of the opt-in letters by the two 
governors also met the conditional approvability requirement for the maintenance plan laid out 
by the EPA in the May 27, 1999 Federal Register. 

Problems arose on November 9, 1999 when the U.S. Court of Appeals for the District of 
Columbia Circuit issued an order to stay the effectiveness of the EPA amendments to 40 Code of 
Federal Regulations (CFR) § 80.70(k). This stay prevented former nonattainment areas such as 
the KCMA from being able to opt- in to the Federal RFG program. 

On January 4, 2000, the same court ruled that EPA exceeded its authority by modifying 
40 CFR § 80.70(k) to allow former nonattainment areas to opt-in to the Federal RFG program. 
As a result of this ruling, the EPA sent a letter to the Governor of Missouri on April 11, 2000. 
This letter informed the State of Missouri that it must select an alternative control strategy to the 
RFG program, and submit a written commitment to the EPA within 90 days. 

As a result of the Court's ruling barring the use of RFG in the spring of 2000, the 
department' s Air Pollution Control Program held three meetings with the petroleum interests 
serving the KCMA. The topic of discussion was the availability of an RFG-like fuel for the area. 
The petroleum industry committed to supplying the KCMA with a 7.0 psi RVP gasoline. This 
gasoline alone would not meet the emissions reductions needed for the maintenance plan. 
Therefore, both Kansas and Missouri needed to investigate stationary sources for additional 
emissions reductions. 

In June of 2000, the AQF voted to reaffirm their recommendation that Stage II Vapor 
Recovery be implemented if a state RFG-like fuel was not available to the KCMA. Also in June 
of 2000, the MARC Board of Directors reaffirmed their commitment to Stage II Vapor 
Recovery. 

On July 7, 2000, Kansas sent a letter to EPA Region VII committing to 7.0 RVP gasoline 
and a cold solvent cleaning rule. Missouri followed up Kansas' s commitments with their own to 



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implement 7.0 RVP gasoline and a cold solvent cleaning rule for their portion of the KCMA. 
The department's Air Pollution Control Program also committed to amending the Stage I Vapor 
Recovery Program in the KCMA to include enhanced reporting and record keeping, increased 
inspection frequency, and installation of pressure vacuum relief valves. 

To comply with the Governor's commitment letter, the department's Air Pollution 
Control Program amended three rules for the 2002 plan. The amendment to rule 10 CSR 10- 
2.330 Control of Gasoline Reid Vapor Pressure changed the summer gasoline RVP requirement 
in the KCMA from 7.2 to 7.0 psi. An amendment to rule 10 CSR 10-2.260 Control of Petroleum 
Liquid Storage, Loading, and Transfer made the changes to the Stage I Vapor Recovery Program 
that the Governor's letter specified. Finally, the amendment to 10 CSR 10-2.210 Control of 
Emissions from Solvent Metal Cleaning required low vapor solvents to be used in cold cleaning 
processes. All of these amendments were approved by the Commission and became effective in 
2001. 

Other control measures were also pursued to meet the required emissions reductions. The 
department's Air Pollution Control Program proposed two new rules that had been identified by 
the 1992 plan. One new rule was 10 CSR 10-2.205 Control of Emissions from Aerospace 
Manufacturing and Rework Facilities. Rule 10 CSR 10-2.215 Control of Emissions from 
Solvent Cleanup Operations was also proposed. These two rules became effective in 2001. 

In addition to rule development, Kansas, Missouri, and MARC worked together to 
develop the 1999 emissions inventory for the KCMA. In January 2002, the EPA released 
MOBILE 6 for use in calculating mobile source emissions. All parties involved agreed to use 
the new MOBILE 6 program to calculate mobile source emissions. On June 11, 2002, the 
MARC Board of Directors approved the mobile budgets. On July 25, 2002, the MACC 
approved the 2002 Maintenance Plan for the Control of Ozone with the mobile budgets 
calculated by MOBILE 6. 

While presenting the 2002 plan to the Commission for approval, the department's Air 
Pollution Control Program informed the MACC that the MARC was compiling a new set of 
population and employment forecasts. When they received all of the updated information, 
MARC would determine if a recalculation of the mobile budget numbers would be required. In 
September 2002, MARC approved the new employment and population forecasts. The 
interagency consulting group and MARC jointly determined that a new area source inventory 



17 



and mobile emissions budget was necessary. MARC approved the new mobile source budget on 
October 29, 2002. The Commission approved the updated budgets on December 5, 2002. The 
2002 Maintenance Plan was subsequently submitted to the EPA. It was found complete in 
December of 2002, and was proposed for approval in the Federal Register on September 16, 
2003. It was given final approval by the EPA on in the January 13, 2004 Federal Register. 
1.5.2 8-Hour Ozone Designation 

During the week of December 9, 2002, the governor of Missouri received a letter from 
the EPA requesting submission of updated, revised, or new designation recommendations and 
documentation by April 15, 2003. This request was to aid the EPA in preparation of the 
designations for the new 8-hour ozone standard. The EPA later extended the deadline for this 
request to July 15, 2003. The department's Air Pollution Control Program recommended that the 
counties of Clay, Platte and Jackson, along with the northern portion of Cass County be 
designated as nonattainment for the 8-hour ozone standard in Kansas City. 

At the same time the states of Kansas and Missouri were preparing the 8-hour designation 
recommendations for the EPA, the MARC AQF determined that a proactive approach to ozone 
reduction would be the most beneficial for the Kansas City area. Therefore, MARC embarked 
on a process that ultimately resulted in a Clean Air Action Plan (CAAP) for Kansas City. This 
plan was developed using a more recent air quality analysis than the previous Maintenance Plan, 
and used the most recent emissions inventory numbers available. This voluntary plan of 
suggested emissions reductions is designed for use as a guide for emissions reductions prior to 
regulation deadlines. It also provides the area with an outline of the options that can assist in 
reducing ozone levels. The CAAP includes an estimate of the amount of reductions for each of 
the suggested emissions reduction possibilities. The MARC submitted the CAAP to the EPA on 
May 10, 2005. In April of 2006, the EPA recognized the Kansas City CAAP with a 2005 Clean 
Air Excellence Award. 

On June 2, 2003, the EPA published the Proposed Rule to implement the 8-Hour Ozone 
National Ambient Air Quality Standard in the Federal Register. In April of 2004, based on the 
most recent ozone data available, the EPA designated the KCMA as "unclassifiable" for the 8- 
hour standard, and indicated that a decision on Kansas City's attainment status would be made 
following the 2004 ozone season. 



18 



Due in part to a mild, wet summer, no exceedances of the 8-hour ozone standard were 
recorded at any of the ozone monitors in Kansas City during 2004. Based on the monitoring data 
from the three-year period of 2002 through 2004, the KCMA was designated as attainment for 
the 8-hour ozone standard. In December of 2004, the department's Air Pollution Control 
Program sent a letter to the EPA certifying the monitoring data for the latest three-year period. 
This letter also requested that the KCMA be designated as an attainment area for the 8-hour 
ozone standard. 

In the May 3, 2005 Federal Register, the EPA issued the Final Rule for the Air Quality 
Redesignation for the 8-Hour Ozone National Ambient Air Quality Standard for Some Counties 
in the States of Kansas and Missouri. This redesignation formally recognized the KCMA as 
being in attainment for the 8-hour ozone standard, effective June 2, 2005. 

Although, the KCMA was designated attainment for the 8-hour standard, the counties of 
Clay, Jackson and Platte continued to be a maintenance area for the one-hour standard. Once the 
8-hour designation was finalized, Missouri and Kansas looked for guidance from the Final Rule 
to Implement the 8-Hour Ozone National Ambient Air Quality Standard - Phase I that was 
published in the Federal Register on April 30, 2004. This rule requires states to submit 
maintenance plans for the 8-hour ozone standard under Section 1 10 (a)(1) of the Clean Air Act 
for areas initially designated as attainment for the 8-hour ozone standard, but that had been in 
violation of the one-hour standard in the past. This maintenance plan has a deadline of 
submission to the EPA of June 15, 2007. The KCMA falls under these requirements. 

In addition to requiring former nonattainment areas to submit maintenance plans, Phase I 
of the 8-Hour Ozone Rule revoked the one-hour ozone NAAQS on June 15, 2005. Because the 
2002 plan for Kansas City only referenced the one-hour standard, it was determined that as a 
transitional measure, the 2002 plan should be revised to include references to the 8-hour 
standard. This transitional plan would ensure that an enforceable SIP was in place during the 
development of the new 8-hour maintenance plan. The transitional plan included the 
contingency measures that had been developed under the one-hour plan, and could be enforced if 
a violation of the new 8-hour standard occurred. The EPA also stated in 69 FR 23985 that "The 
maintenance plan requirements [for the one-hour ozone standard] will remain enforceable as part 
of the approved SIP until such time as the EPA approves a SIP revision removing such 
obligations." Thus, although the one-hour standard was revoked, the contingency measures and 



19 



triggers associated with the one-hour standard remain in effect until a new SIP replaces these 
contingency measures and associated triggers is approved. 

The 2005 Maintenance Plan for the Control of Ozone was adopted by the MACC on July 
21, 2005 and submitted to the EPA on September 6, 2005. The EPA issued its final approval of 
this maintenance plan in the June 26, 2006 Federal Register. 

1.6 Current Ozone Maintenance and Contingency Planning 

After the transitional plan was completed, work began on the new 8-Hour Maintenance 
Plan for the KCMA. Discussions were held between the states of Kansas and Missouri to 
establish a tentative outline for the organization of the plan, as well as the emissions inventory 
and potential modeling of a new episode for the area. An Ozone Technical Workgroup was 
created by the AQF to provide the opportunity for concerned stakeholders from the Kansas City 
area to take part in the creation of the Maintenance Plan that would act as the air quality 
guidance for the KCMA until 2014. 

Due to the KCMA's current status as an attainment area for the 8-hour standard, one of 
the main focuses of the plan was the contingency measures and associated triggers. A number of 
workgroups and meetings were held with sources that would be effected by contingency 
measures. These meetings provided companies the opportunity to discuss their reactions to the 
proposed contingency control measures. It also allowed those regulating the industries the 
opportunity to communicate their goals and plans for various contingency control measures. The 
final outcome of all of the meetings and workgroups was a contingency control measures list that 
included a variety of control measures that would impact sources of both VOCs and NOx. 

This document and its attachments are the result of this collaborative process, and is the 
8-Hour Maintenance Plan for the Control of Ozone for the Kansas City Maintenance Area. It 
was prepared to fulfill the EPA's requirements. This plan is intended to replace the transitional 
plan that was developed in 2005. 

2.0 REQUIREMENTS 



20 



2.1 Clean Air Act Requirements 

The KCMA is in a somewhat unique position due to its maintenance status under the 
previous one-hour ozone standard and as an attainment area under the current 8-hour standard. 
The EPA recognized that a number of areas would be in the same position when they published 
Phase I of the 8-Hour Ozone NAAQS. Therefore, the rulemaking established Sections 51.905 
(c) and (d) that set forth anti-backsliding requirements for areas such as the KCMA. These 
provisions require these areas to submit a 10-year maintenance plan under Section 110 (a)(1) of 
the CAA if they were a nonattainment area, or an attainment/unclassifiable area with a Section 
175 A maintenance plan under the one-hour ozone standard. 

The 8-Hour Ozone Maintenance Plan under Section 110 (a)(1) of the CAA, constitutes a 
SIP revision. The plan must provide for the continued maintenance of the 8-hour ozone NAAQS 
for 10 years from the effective date of the KCMA's designation as unclassifiable/attainment for 
the 8-hour ozone standard. It must also include contingency control measures that would be 
implemented as a result of a violation of the 8-hour ozone standard. Guidance provided by the 
EPA to aide states in the development of this maintenance plan recommend that the plan include 
the following elements: 

1) Attainment Inventory - An inventory based on a typical summer day of emissions of 
VOCs and NOx. As suggested by the EPA, the inventory developed for the 2002 
Consolidated Emissions Reporting Rule was used as the attainment emission 
inventory base year for the maintenance plan. 

2) Maintenance Demonstration - It must show how the area will remain in compliance 
with the 8-hour ozone standard for the 10 year period following the effective date of 
designation as unclassifiable/attainment. Therefore, the plan must project attainment 
through 2014. 

3) Ambient Air Quality Monitoring - Missouri and Kansas agree to operate air quality 
monitors in accordance with 40 CFR 58 to verify maintenance of the 8-hour standard 
in the area. Any proposed network modifications must be accompanied by technical 
and statistical analysis sufficient to document the need to remove, move or add 
monitors. 



21 



4) Contingency Plan - Both states must develop a contingency plan that will, at 
minimum, ensure that any violation of the 8-hour ozone standard is promptly 
corrected. The plan must also assure that the contingency measures are adopted 
expeditiously once they are triggered. The EPA expects the plan to clearly identify 
the measures to be adopted, including a schedule and procedure for adoption and 
implementation, and offer a specific time limit for action by the States. A maximum 
time limit of 24 months for adoption and implementation of contingency measures is 
anticipated by the EPA. In addition, both Kansas and Missouri must identify specific 
indicators, commonly referred to as "triggers", to be used to determine when 
contingency measures need to be adopted and implemented. 

5) Verification of Continued Attainment - This verification is an indication of how the 
two states will track the progress of the maintenance plan. Verification is necessary 
based on the fact that the emissions projections made for the maintenance 
demonstration are based on assumptions of point, area, and mobile source growth. 

By verifying the assumptions on a periodic basis, States are assuring that the area is in 
attainment during the entire 10-year maintenance period, not just showing that the 
area will again be in attainment at the end of the 10-year time period. 
In addition to the above requirements, the KCMA must keep all of the controls that are in 
place for maintaining the one-hour standard. According to Phase I of the 8-hour Rule, an area 
must first submit a Section 110 (a)(1) maintenance plan before a revision to make any changes to 
the one-hour controls or contingency measures is considered. At that time, any modifying or 
removing of one-hour controls must be done under Section 1 10 (1) of the CAA. 

2.2 Administrative Requirements 

2.2.1 Legal Authority 

The Missouri Air Conservation Commission is granted the legal authority to develop and 
implement regulations regarding air pollution under section 643.050 of the Revised Statues of 
Missouri. 



22 



2.2.2 Public Hearing Notice and Certification 

The department's Air Pollution Control Program is required to announce a public 
hearing, at least 30 days prior to holding such a hearing. Announcements were submitted to 
newspapers at least 30 days prior to the public hearing. The public hearing for this maintenance 
plan occurred on March 29, 2007. Attached in Appendix B is the public hearing notice, along 
with certification of publication of the public notice for the maintenance plan. 

2.2.3 Comments, Responses, and Explanations of Change 

Attached in Appendix C are the department' s Air Pollution Control Program responses to 
comments received during the open public comment period for this maintenance plan. The 
comment period was open until April 5, 2007, seven days after the Public Hearing that was held 
on March 29, 2007. The department's Air Pollution Control Program is required to respond to 
all comments received by either amending the plan or explaining the reasoning for not making an 
amendment. 

2.2.4 MACC Adoption Certification 

Attached in Appendix D is the MACC adoption certification to demonstrate the approval 
of the Maintenance Plan by the Commission. 

2.2.5 Commitment to Revise Plan 

Under Phase I of the 8-Hour Ozone NAAQS, a maintenance plan is only required for the 
first 10 years following designation under the 8-hour standard. It does not require a second 10- 
year maintenance plan as is required for areas subject to a Section 175 A maintenance plan. 
However, contingency plans approved as part of the Section 110 (a)(1) maintenance plan remain 
in effect, and if the area violates the 8-hour standard after the initial 10-year period, contingency 
measures could still be triggered. The department's Air Pollution Control Program recognizes 
the importance of an up-to-date, current maintenance plan, and commits to updating it as 
necessary. 

3.0 CONTROL MEASURES 

3.1 Current Control Measures 



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The 2007 Kansas City 8-Hour Maintenance Plan for the Control of Ozone shows, without 
the addition of any new control measures, that ozone precursor emissions will be reduced 
between the base year of 2002 and the projected attainment year of 2014. In fact, the projected 
inventory for 2014 shows a decrease in both NOx and VOC emissions for the KCMA. These 
reductions are the result of a number of rulemakings whose implementation has occurred 
between the 2002 base year inventory and the 2014 attainment year inventory. 

3.1.1 Federal Control Measures 

There are a number of emissions control measures that were developed on a federal level 
and implemented after 2002, and will become effective by the 2014 attainment date. The net 
result of these emissions control rules were included in the 2014 projection by adjusting the 
default growth values in the inventory. These rulemakings include: 

Tier 2 Vehicle and Gasoline Sulfur Program 

2007 Highway Rule - Heavy Duty Diesel Engines and Ultra Low Sulfur Diesel (ULSD) 
ULSD requirement increase to include all refiners and the offroad diesel supply 
Onboard Refueling Vapor Recovery (ORVR) - Light truck models 
Clean Air Interstate Rule - NOx reductions for Electric Generating Units 
The majority of these federal control measures affect onroad mobile sources. One 
measure, the Clean Air Interstate Rule (CAIR) affects large stationary sources. CAIR decreases 
emissions at power plants, referred to as electric generating units (EGUs). EGUs with a 
generator nameplate capacity greater than 25 megawatts fall under CAIR's regulations. CAIR is 
an EPA rulemaking that permanently caps sulfur dioxide and NOx emissions in the eastern 28 
states, including Missouri. According to the EPA Fact Sheet for CAIR, once CAIR is fully 
implemented, the EPA estimates that CAIR will reduce NOx emissions by over 60 percent from 
2003 levels. Under CAIR, Missouri will require all EGUs to participate in an EPA administered 
cap and trade system that caps emissions in two stages. Stage I controls for annual NOx 
emissions reductions must be in place by January 1, 2009, and Stage I controls for ozone season 
NOx emissions reductions must be in place by May 1, 2009. Stage II emission reduction 
controls for annual NOx and ozone season NOx emission reductions must be in place by January 
and May of 2015, respectively. EPA's Fact Sheet for CAIR estimates that the first stage of 
CAIR will result in over 50% reductions in NOx emissions from affected EGUs. 



24 



3.1.2 State Control Measures 

The state of Missouri has previously adopted a number of control measures to reduce the 
VOC emissions in the KCMA. These measures were enacted in order to achieve and maintain 
the previous one-hour standard. These measures include a series of VOC emission control rules. 
The VOC emission reduction rules are designed to aid in reducing VOCs from stationary 
emission sources. Another VOC reducing rule that is specific to the KCMA focusing on mobile 
sources is the 7.0 psi low RVP fuel rule. Most of these rules have been in effect long enough 
that their reductions are reflected in the 2002 base inventory. Those rules that included deadlines 
for emissions reductions that were required after 2002 were taken into account by adjusting the 
projected 2014 emissions inventory. A list of the current state regulations that apply only to the 
KCMA can be found in Appendix E. 

3.2 Voluntary Control Measures 

3.2.1 Clean Air Action Plan 

The department's Air Pollution Control Program, along with MARC and KDHE has 
continued to foster the implementation of voluntary measures to aid in reducing the emissions of 
VOCs and NOx in the KCMA. As an example, a Clean Air Action Plan (CAAP) was created for 
the region. The CAAP can be found in Appendix F. The CAAP represents a comprehensive, 
community based voluntary strategy for reducing ground level ozone pollution in the KCMA. 
The metropolitan Kansas City area has a long history of working to improve its air quality 
through both regulatory and voluntary measures, but the CAAP represented the first time that the 
region had worked to develop a systematic and comprehensive clean air strategy outside of a 
regulatory framework. The CAAP's goal is to reduce ozone-forming emissions earlier than 
required under regulatory timelines in order to increase the likelihood that the region will stay in 
compliance with the 8-hour ozone standard. 

At the end of 2003, when a violation of the 8-hour standard appeared imminent, the 
MARC AQF created a 12-member Air Quality Working Group (AQWG) to oversee the 
development of the CAAP for the Kansas City region. The group consisted of four elected 
officials, four representatives of business and regulated industry, and four community group 



25 



representatives. A technical advisory group consisting of staff from KDHE, the department's 
Air Pollution Control Program and local agency staff supported the AQWG. 

3.2.1.1 Modeling 

As part of the CAAP, the AQWG set an aggressive meeting schedule and in February of 
2004 embarked on a mission to better understand the region's ozone problem. With assistance 
from the department's Air Pollution Control Program and KDHE, MARC contracted with 
Sonoma Technologies, Inc. to provide additional technical support in evaluating control strategy 
options and conducting a photochemical modeling analysis of 8-hour ozone values in the Kansas 
City region. The modeling was also used to evaluate measures that could be used to reduce 
emissions. 

A specific historical period with high ozone concentrations was selected as a 
representative episode, and an emissions inventory for that time period was developed. Once the 
model was run for the specific historical period, an evaluation of the simulations was made in 
accordance with the EPA guidelines. Comparisons of model-predicted ozone levels were made 
with ambient air quality data to determine how closely ozone concentrations predicted by the 
model corresponded to observed concentrations. The model predicted ozone concentrations 
quite well at all sites and for most hours of the day with a few exceptions. The model did tend to 
under predict the ozone levels at night in the urban core. The deviations did not reach a level of 
concern and the overall model performance statistics met the EPA's criteria for acceptance. 

Once it was established that the air quality modeling system was adequately reproducing 
ozone levels for the historic episode, the model was rerun with future projected emissions for 
2010. This run did not include any local controls. The model predicted the ozone design value 
for 2010 would fall just below the 8-hour standard. Because the predicted ozone design value 
was close to the 8-hour standard, it was determined that using the model to assess various control 
strategies to reduce emissions that lead to ozone formation in the KCMA would be a valuable 
exercise. 

The photochemical model was used to assess various groups of control strategies. Of the 
strategies modeled, reducing NOx emissions from EGUs was shown to have the greatest effect 
on lowering ozone concentrations in the KCMA. Voluntary measures were also shown to help 
reduce the potential for ozone formation. 



26 



3.2.1.2 Approval and Submission of CAAP 

The AQF and MARC Board of Directors approved the CAAP in March of 2005. The 
CAAP was submitted to the EPA Region 7 on May 15, 2005. In April of 2006, the EPA 
recognized the CAAP with a 2005 Clean Air Excellence Award. This award is given to 
recognize and honor outstanding, innovative efforts that help to make progress toward achieving 
cleaner air. 

3.2.1.3 CAAP Measures Implemented 

In accordance with the CAAP, MARC has hosted a number of workshops to inform small 
businesses on innovative methods to decrease their VOC and NOx emissions. These workshops 
have focused on area emissions sources such as commercial lawn and garden maintenance, 
printing, and autobody painting. Public education and outreach has continued to inform both 
companies and individuals on what they can do to reduce their emissions on high ozone days. 
MARC has begun to focus on the more long term planning aspects of the CAAP. Transportation 
has been chosen as the main focus. MARC believes that it offers the most beneficial 
opportunities for long term air pollution reduction. 

4.0 MONITORING NETWORK 

4.1 Ozone Monitoring Network 

The KCMA ozone monitoring network consists of eight monitors. Assuming winds are 
predominantly from the south, two monitors are placed downwind, north and east of Kansas 
City, in Liberty, Missouri and in Watkins Mill Park. They are situated to record the peak 
afternoon readings. Another monitor is placed in a populated area, at Rocky Creek, Missouri 
(moved from Worlds of Fun in 2002). A fourth monitor is placed upwind in the prevailing 
summer wind patterns, south of Kansas City at Richards Gebaur Airport. The purpose of the 
monitor at Richards Gebaur is to monitor ozone transport from outside the metropolitan area. 
One monitor is located in the downtown area, on 10 th Street in Kansas City, Kansas, Wyandotte 
County. For the 2003 ozone season, two additional monitors were added. These two monitors 
provide additional monitoring on the Kansas side, in the outlying suburban areas at the U.S. 



27 



Penitentiary in Leavenworth, Kansas, and at Heritage Park in Olathe, Kansas. An eighth monitor 
was added for the 2004 ozone season. This monitor is located in the southwest corner of Clinton 
County, in Trimble, Missouri. This monitor measures ozone levels just north and east of the 
maintenance area. A map in Appendix Gl shows the locations of the monitors in and around the 
KCMA. 

Various organizations are responsible for the maintenance of the monitors in the 
monitoring network. The department's Air Pollution Control Program maintains the operation of 
the Liberty, Rocky Creek, Trimble and Watkins Mill Park locations. The monitor in Kansas 
City, Kansas is operated by the Wyandotte County Department of Air Quality. Two monitors 
are operated by KDHE's Bureau of Air and Radiation, at the U.S. Penitentiary in Leavenworth, 
Kansas and at Heritage Park in Olathe, Kansas. For the 2006 ozone season, one monitor was 
removed from the monitoring network. This monitor was located at the Kansas City 
International Airport (KCI). The KCI monitor had been in use since 1969. The site was 
discontinued based on the EPA's recommendations from the Kansas City metropolitan area's 
monitoring network review. This review also resulted in the movement of a monitoring site from 
World's of Fun to Rocky Creek. 

4.2 Ambient Air Monitoring 

As previously mentioned, exceedances of the standard are determined on a per monitor 
basis. An exceedance of the standard occurs any time that an 8-hour average value is greater 
than 0.084 ppm. A monitor can exceed the 8-hour standard and not violate the standard. A 
violation of the standard at a specific monitor is determined by taking the fourth-highest, eight- 
hour average reading at a monitor for each of three consecutive years and averaging them 
together. The eight-hour ozone standard is 0.08 ppm and, due to rounding, a monitor must have 
a fourth highest eight-hour, three-year average reading of 0.085 ppm or higher for it to be 
considered a violation of the standard. 

Appendix G2 lists the values for the four highest exceedances of the eight-hour standard 
annually at each monitor and the total number of exceedances the monitor recorded each year. 
In order to show a more historical perspective of the 8-hour standard, the readings include 8-hour 



28 



monitoring data beginning with the 1997 ozone season when the 8-hour ozone rule became 
effective, or the year the monitor was installed. 

Since 2002, the KCMA has experienced 8 1 exceedances of the eight- hour ozone 
standard. Twenty-five exceedances of the eight-hour standard were recorded in 2002, followed 
by 27 in 2003. Due in part to a mild, wet summer, the 2004 ozone season recorded no 
exceedances of the eight-hour standard. In the 2005 ozone season, 29 exceedances were 
recorded. The values of the exceedances for the eight- hour standard have ranged from 0.1 15 
ppm to 0.085 ppm. For comparative purposes, the total number of exceedances recorded each 
year since 1997 at all monitoring locations appears in Appendix G3. 

4.3 Monitoring Based Attainment Demonstration - Design Values for the KCMA 

Design values are used as indicators of a region's air quality. A design value is the 
indicator of the known ozone value for a monitor, and provides a value for comparison with 
actual measurements during the ozone season. A specific monitor's design value under the 8- 
hour standard is determined by taking the fourth highest eight-hour average reading at a monitor 
for each of three consecutive years and averaging them together. The higher a design value for 
an area, the poorer the air quality. Along the same lines, if an area shows an increasing design 
value over a number of years, monitoring data is indicating that the air quality is worsening. 

The design value for the KCMA is determined by comparing all of the design values for 
the monitors in the maintenance area. The area's design value is determined by the highest 
individual monitor's design value for each three-year averaging period. The area's status of 
attainment or nonattainment is determined by this design value. For the eight-hour ozone 
standard, the design value for the three-year time periods from 2002 through 2005 do not exceed 
0.085 ppm, and thus achieve attainment for the KCMA. Appendix H includes the design values 
for the eight-hour standard for each of the three-year design value time periods between 1997 
and 2005. 

4.4 Missing Data Under the Eight-Hour Ozone Standard 



29 



Eight-hour ozone attainment is determined by a three-year average of the annual fourth 
highest daily maximum. Missing days are of importance only in determining whether sufficient 
data was sampled to determine compliance. A monitoring day must include 18 valid eight- hour 
averages for a daily maximum to be determined. To calculate a design value, an average of 90% 
of the possible daily maximums over a three year period must be complete, with no one year 
having less than 75%. The final result is that no more than 53 missed days in one year, or 64 
missed days total for the three-year period are allowed. If these criteria are not met, then 
compliance with the 8-hour ozone standard cannot be established. To date, acceptable monitoring 
has been maintained in the Missouri portion of the KCMA for the 8-hour ozone standard. 

4.5 Quality Assurance Program 

The department's Air Pollution Control Program and KDHE quality assure all data that 
appears in the tables found in Appendices G2 and G3 in accordance with 40 CFR 58.10 and both 
departments' Quality Assurance Plans and Standard Operating Procedures. These two 
documents describe the proper procedures for the operation of the ambient air monitoring 
networks as well as how the data must be validated. The department's Air Pollution Control 
Program and KDHE are required to record the data into the EPA's Air Quality System (AQS) 
database, which is made available to the public. 

4.6 Continued Ambient Air Monitoring 

The department's Air Pollution Control Program commits to continue monitoring ozone 
levels according to an EPA approved monitoring plan. This monitoring is required by the EPA 
to ensure maintenance of the 8-hour ozone standard for the next ten years. Should any changes 
concerning the location of a monitoring station become necessary, the department's Air Pollution 
Control Program will work cooperatively with the EPA to ensure the adequacy of the monitoring 
network is maintained. The department's Air Pollution Control Program will continue to quality 
assure the monitoring data in order to meet the requirements of 40 CFR 58. The department's 
Air Pollution Control Program will continue to enter all monitoring data into the EPA's AQS 
database on a timely basis in accordance with federal guidelines. 



30 



5.0 EMISSIONS INVENTORY 

5.1 Attainment and Projected Inventory 

An emissions inventory is an itemized list of emission estimates for sources of air 
pollution in a given area for a specified time period. The two main or most important pollutants 
that lead to the formation of ground level ozone are VOCs and NOx. The KCMA is currently in 
attainment for the 8-hour ozone standard. The main objective of the emissions inventory is to 
support the revisions of the KCMA's Maintenance Plan as required by the CAA Section 1 10 
(a)(1) and the EPA's Phase I Implementation Rule for the 8-hour ozone standard. In addition, 
this emissions inventory may be used in future regional ozone modeling applications. 

The Phase I Implementation Rule provides that the 10-year maintenance period began as 
the effective date for the initial designation of the area under the 8-hour ozone standard. The 
effective date for the initial designation of unclassifiable for the KCMA was June 15, 2004. 
Therefore, emissions for the KCMA must be projected to 2014. States were given the option of 
choosing one of the three years that the 8-hour attainment designation is based upon (2001, 2002 
and 2003). Since the states were required to develop and submit an complete emission inventory 
for the 2002 National Emissions Inventory (NEI) under the EPA's Consolidated Emissions 
Reporting Rule (CERR) (40 CFR Part 51), Missouri chose to use 2002 as the attainment 
emission inventory base year for the Section 1 10 (a)(1) maintenance plan. 

Besides the KCMA, Missouri also has the city of St. Louis and its surrounding counties 
with a history of ozone air quality issues. Section 182 (a)(3)(B) of the 1990 CAAA requires all 
states with ozone nonattainment areas to require emissions statements from sources of VOC and 
NOx. In January 1994, the department submitted a revision to the Missouri SIP that 
demonstrated compliance with this requirement. Since that time, the annual reporting forms that 
individual companies use to report their emissions have gone through a number of revisions. 
The reporting requirements associated with these forms are specified in 10 CSR 10-6.110, 
Submission of Emission Data, Emission Fees, and Process Information. These reporting forms 
are known as Emissions Inventory Questionnaires (EIQs). 



31 



EIQs provide the mechanism by which the department collects the information required 
by Section 182 (a)(3)(B) of the CAAA. The information provided by companies includes the 
name, location, address, geographical location, industrial classification codes, and the 
operational activity and process rates throughout the year. The forms also require the 
identification of emissions controls and control efficiencies, as well as emissions factors and 
emissions calculations methods used. The forms also provide the necessary certification from 
the sources that the data is accurate. 

The department's Air Pollution Control Program prepared an inventory for the 2002 NEI 
as required by the CERR. However, subsequent to submitting the data to the 2002 NEI, 
substantial revisions and improvements were made to the point, area, and offroad mobile source 
emissions through the Central Region Air Planning Association (CENRAP) workgroup process 
for regional haze planning and analysis. In addition, the department developed updated 2002 
onroad mobile emissions estimates for the base year inventory using more current input data, 
based on the latest MARC vehicle miles traveled (VMT) estimates. The 2002 base year 
inventory for the KCMA is a composite of inventory data prepared by the department's Air 
Pollution Control Program and data generated through the CENRAP process. 

This inventory is comprehensive and current for all 2002 actual emissions of the 
pollutants that contribute to ozone formation in the KCMA. The inventory addresses emissions 
of VOCs, NOx and carbon monoxide (CO) from stationary point and area sources, onroad and 
offroad mobile sources, and biogenic sources for all five counties of the KCMA. This attainment 
inventory is based on actual typical ozone season day (OSD) emissions. Ozone season day 
emissions are defined as emissions occurring during a typical weekday during the high ozone 
season, which is June through August. Emissions for all categories were calculated for 2002 and 
2014 in tons per OSD. 

The 2002 KCMA base emissions inventory was a cooperative effort. In addition to the 
work completed through the CENRAP workgroup process that has been incorporated, MARC, 
KDHE, and the department's Air Pollution Control Program also made contributions. MARC 
provided the onroad VMT data for the five county KCMA. The department's Air Pollution 
Control Program developed all of the emissions estimates for all point, area, offroad and onroad 
mobile categories based on information provided by MARC and KDHE. KDHE developed the 
biogenic emissions for the counties in the KCMA. 



32 



5.2 Anthropogenic Emissions 

Anthropogenic emissions are emissions resulting from human activities and are broadly 
classified into the point, area, offroad mobile and onroad mobile source types. 
5.2.1 Point Source Emissions 

5.2.1.1 Point Source Emission Description 

Point sources are large, stationary, identifiable sources of emissions. The department 
defines point sources as sources with a Basic, Intermediate or Part 70 operating permit that must 
report their actual emission to the department on an annual basis through the EIQs that are 
described in the previous section. 

The 2002 point source inventory is based on the 2002 EIQs submitted by facilities. The 
2002 EIQ data collection process was conducted by the department's Air Pollution Control 
Program and the local air pollution agencies of St. Louis County and the cities of St. Louis, 
Springfield and Kansas City. As the coordinating agency for point source inventory 
development, the department' s Air Pollution Control Program performed the overall quality- 
assurance procedures and submitted the data to the 2002 NEI to meet the requirements of the 
CERR. 

Following submission of the Missouri point source inventory to the 2002 NEI, additional 
quality assurance and revision of the data was completed through the CENRAP process. Pechan, 
through a contract with CENRAP, obtained the Missouri point source inventory and worked with 
the department's Air Pollution Control Program to make corrections where needed. In 
particular, an error that resulted in the double-counting of emissions from a number of emissions 
units was corrected. Other revisions included corrections to facility coordinates and stack 
parameters. Pechan also converted the point source inventory to the Sparse Matrix Operator 
Kernel Emissions / Inventory Data Analyzer (SMOKE/IDA) format. Pechan' s work is described 
in detail in the two documents The Consolidation of Emissions Inventories (April 28, 2005) and 
Refinement of CENRAP 's 2002 Emissions Inventories (August 31, 2005). These two documents 
can be found in Appendix I and Appendix J respectively. 



33 



The SMOKE/ID A-formatted file prepared by Pechan was considered to be the most 
accurate and current version of the 2002 Missouri point source inventory and therefore was used 
as the basis for the base and projected year inventories summarized in this document. The file 
contained the annual emissions for all point sources and ozone season day emissions where this 
information was provided in EIQs. Because ozone season day emissions information was not 
complete, the SMOKE model was used to calculate typical ozone day emissions for almost all 
point sources in the KCMA in order to apply consistent procedures to all sources. An 
explanation of how the typical ozone season day was calculated can be found in Appendix K. 

5.2.1.2 Point Source Emissions Projection Year Calculation 

The ozone season day emissions data available from EIQs and SMOKE model 
calculations were used to determine the emissions levels for the future attainment year of 2014. 
To project the future emissions levels, the EPA's Economic Growth Analysis System (EGAS) 
v5.0 software was used to determine the growth factors for all emissions sources. EGAS v5.0 
allows the user to first set the base year of the known emissions. The future year is then chosen 
and EGAS calculates the growth factor based on Source Classification Code (SCC) and county 
codes for all emissions sources. The following equation can then be used to determine the 2014 
emissions levels from all point sources: 

2014 OSD emissions = 2002 OSD emissions x 2014 growth factor 

This calculation was done on most of the point sources to project their emissions. There 
were a small number of point sources that had undergone significant changes since the 2002 
emissions inventory. Kansas and Missouri identified those point sources that had either closed, 
added emissions control devices, or recently opened. Depending on the status of the point 
source, the emissions from these sources were removed, reduced or added to the inventory for 
the 2014 projected emissions. The number of sources that had significant changes that required 
adjustments to their emissions inventory totaled less than ten for the five county KCMA. 

The only source category that was calculated differently from the basic growth method 
was the projected emissions from EGUs. Due to the dramatic changes in the energy sector 
between 2002 and 2005, it was determined that the 2005 data was more representative for current 
and future emissions from various EGUs rather than 2002 emissions data. Therefore, 2005 
emissions year data was used in place of 2002 emissions source data for EGU emissions 



34 



projections in the KCMA. The 2005 point source EGU emissions data was then used to 
calculate the 2014 projected emissions using the same growth factor calculation listed above. 
After the 2014 projected emissions were calculated for the EGUs, the future effects of the CAIR 
restrictions were factored in. CAIR is an EPA rulemaking that affects EGUs in 28 eastern states 
in the United States, including Missouri. It limits the emissions levels of NOx through a cap and 
trade program. As previously mentioned, CAIR has two deadlines for emissions reductions in 
2009. The first level of emissions reductions can be achieved in a variety of ways. The options 
include the addition of controls, retiring a unit, reducing the load on a unit or purchase of credits 
from other sources. In addition, a utility company can over control emissions at one source, and 
then transfer the excess credits to a second unit that is under controlled, thus balancing out the 
company's overall emissions. Therefore, for those EGUs in the KCMA affected by CAIR, their 
emissions levels were limited to the 2009 allocation amount in the 2014 attainment inventory. 
For additional information on CAIR, please see the Current Control Measures - Federal Control 
Measures section. 

A comparison of the point source emissions for a typical ozone season day in 2002 versus 
a typical ozone season day in 2014 reflects a large decrease in NOx emissions, and a slight 
increase in VOC emissions. Appendix LI lists the typical ozone season day emissions for point 
sources in the Missouri portion of the KCMA. This data includes the typical summer day 
emissions for VOCs, NOx and CO by 2-digit Standard Industrial Code (SIC) categories for 2002 
and 2014. This table is sorted from highest to lowest VOC emissions. Appendix L2 lists the 
typical ozone season day emissions for the point sources in the Missouri portion of the KCMA 
for VOCs, NOx and CO by individual companies for 2002 and 2014. It is sorted from highest to 
lowest by VOC emissions. Appendix L3 lists the ozone season day emissions from EGUs in the 
Missouri portion of the KCMA. It is sorted from highest to lowest by NOx emissions. 
Appendix L4 lists the Kansas portion of the KCMA point source emissions data by 2-digit SIC 
categories. 

5.2.2 Area Source Emissions 

5.2.2.1 Area Source Emissions Description 

Area sources are stationary sources that do not qualify as point sources under the relevant 
emissions cutoffs. Area sources encompass more widespread sources that may be abundant but 



35 



individually release small amounts of a given pollutant. Examples of area sources include 
autobody painting, fires, dry cleaners, and consumer solvent use. 

The 2002 area source inventory is a consolidation of the best available area source 
emissions data. It includes emissions estimates prepared by the department's Air Pollution 
Control Program and CENRAP, with remaining gaps filled in with data from the EPA's NEI. 
For the categories developed by the department's Air Pollution Control Program, the data and 
methods used are described in the document Missouri Stateside Estimates for the 2002 National 
Emissions Inventory (NEI): Area Sources. This document can be found in Appendix M. The 
data and methods used to develop the prescribed burning inventory for CENRAP are discussed 
in Sonoma Technology's report Research and Development of Planned Burning Emission 
Inventories for the Central States Regional Air Planning Association (July 30, 2004). Sonoma 
Technology's report is located in Appendix N. Documentation of the EPA's methods for the 
NEI may be found on the EPA's Clearinghouse for Inventories and Emissions Factors (CHIEF) 
website at http://www.epa.gov/tnn/chief/net/2002inventory.html . 

In a contract with CENRAP, Pechan consolidated the area source data from the various 
sources, conducted additional quality assurance, and worked with department's Air Pollution 
Control Program to make revisions where needed. In particular, corrections were made to a 
double-counting error of industrial surface coating VOC emissions. Pechan also converted the 
area source inventory to the SMOKE/IDA format. Pechan' s work is described in detail in the two 
documents The Consolidation of Emissions Inventories (April 28, 2005) and Refinement of 
CENRAP' s 2002 Emissions Inventories (August 31, 2005). 

The SMOKE/ID A-formatted file prepared by Pechan was considered to be the most 
accurate and current version of the 2002 Missouri area source inventory and was used as the 
basis for the base and projected year inventories summarized in this document. The file 
contained the annual emissions for all area sources and ozone season day emissions for some 
categories. Because ozone season day emission information was not complete, the SMOKE 
model was used to calculate typical ozone day emissions for all area sources in the KCMA in 
order to apply consistent procedures to all sources. 



36 



5.2.2.2 Area Source Projection Year Calculation 

The ozone season day emissions data available from the SMOKE model calculations 
were used to determine the emissions levels for the future attainment year of 2014. To project 
the future emissions levels, the EPA's EGAS v5.0 software was used to determine the growth 
factors for all emissions sources. EGAS v5.0 allows the user to set the base year of the known 
emissions. The future year is then chosen and EGAS calculates the growth factor based on SCC 
and county codes for all emissions sources. The following equation can then be used to 
determine the 2014 emissions levels from all area source categories: 

2014 OSD emissions = 2002 OSD emissions x 2014 growth factor 

After area source category emissions were calculated, regulations that were enacted after 
2002 were factored into the calculation for some area source emissions. These controls were 
implemented as a result of previous ozone violations, and result in additional emissions 
reductions that were not taken into account by the initial inventory. Two regulations that were 
enacted after 2002 that affect the KCMA are 10 CSR 10-2.215 Control of Emissions from 
Solvent Cleanup Operations and 10 CSR 10-2.260 Control of Petroleum Liquid Storage, Loading 
and Transfer. These regulations apply only to the KCMA and only affected a few SCC codes. 
Some portions of the federal ORVR requirements that have been enacted on a rolling basis have 
also reduced emissions from some area SCC categories. These adjustments were taken into 
account by the following equation: 

2014 adjusted OSD emissions = 2014 OSD emissions x (l-[(CE)x(RE)x(RP)]/1000000) 
where CE is the control efficiency of the rule, RE is the rule effectiveness, and RP is the rule's 
penetration, all in percentages. Control efficiency represents the amount of a source category's 
emissions that are controlled by a control device, process change, or reformulation. CE values 
for area sources represent the weighted average control for the category. Rule effectiveness is an 
adjustment to the CE to account for failures and uncertainties that affect the actual performance 
of the control. The EPA recommends a default value of 80 percent for RE, if information cannot 
be acquired to substantiate the true value of RE. If controls are irreversible process changes or 
reformulations, RE can be set at 100 percent. Rule penetration is defined as the percentage of 
the area source category that is covered by the applicable regulation or is expected to be 
complying with the regulation. The RP value can be based on a percentage of the source 
category that is covered by a regulation. 



37 



A comparison of typical ozone season day area source emissions for the 2002 ozone 
season versus the 2014 ozone season reflects an increase in VOCs and a slight increase in NOx. 
Appendix 01 provides a list of the Missouri portion of the KCMA area source emissions by 2- 
digit SIC code listed in order from largest to smallest VOC sources. Appendix 02 lists the 
Kansas portion of the KCMA area source emissions. 

5.2.3 Onroad Mobile Source Emissions 

5.2.3.1 Onroad Mobile Source Emissions Description 

Onroad mobile sources include motor vehicles such as cars, vans, trucks, buses, and 
motorcycles that are used for transportation of passengers and goods on public roads and streets. 
Internal combustion (IC) engines power nearly all mobile sources other than jet or turboprop 
aircraft. IC engines can be either spark-ignition engines such as those found in most 
automobiles, or compression-ignition (diesel) engines such as those found in larger (heavy duty) 
trucks. Almost all mobile sources use liquid fuels such as gasoline or diesel fuel. 

5.2.3.2 Onroad Mobile Source Emissions Calculation 

The department's Air Pollution Control Program used the Mobile 6.2 model to estimate 
onroad vehicle emissions for the 2002 base year inventory and the 2014 projected year inventory 
for both the Kansas and Missouri portions of the KCMA. Input file information was adjusted to 
reflect the 7.0 RVP fuel requirement for the KCMA, as well as the maximum, minimum and 
mean temperature data for the ozone season. Temperature information was obtained from the 
Weather Channel's website at www.weather.com . For the 2014 projected emissions, the Mobile 
6.2 model is designed to take into account any federal control measures that will result in a 
decrease in emissions. Appendix PI provides a table of the settings that were changed from the 
default Mobile 6.2 values. Additional information on what federal control measures may result 
in emissions reductions can be found in the Current Control Measures - Federal Control 
Measures section. The Mobile model provides an emissions rate in grams/mile. 

The 2002 and 2014 VMT county data for the each of the five counties in the KCMA was 
obtained from MARC in July of 2006. MARC developed the average daily VMT estimates for 
each county for both 2002 and 2014 using the EMME/2 regional travel demand model. 
EMME/2 was validated against 1998 average daily traffic counts and count-derived VMT to 
determine whether it reasonably reflects vehicular travel patterns. Some factoring of model- 



38 



based assignments and/or count data was required because the regional travel demand model 
estimates are for the year 2000, consistent with MARC's regionally adopted forecasts for 
population and employment. The validation of the EMME/2 included a review of the network 
coding and a check of the accuracy of counts used for validation, as best as possible, versus 
available historical counts. Network estimated traffic speeds generated by EMME/2 were also 
checked versus recently observed values. Seasonal adjustments were made to the average daily 
VMT based on summer travel information from the Missouri and Kansas Departments of 
Transportation. The VMT data for each county in the KCMA can be found in Appendix P2 

In order to determine the typical ozone season daily emissions, the Mobile 6.2 emissions 
rate is converted to tons/mile and multiplied by the VMT for each county. The following 
equation was used to determine the OSD emissions: 

2002 onroad emissions = 2002 emissions rate (g/mi.) x (1 ton/907 184.74g) x VMT for county 
The individual county emissions were then added together to determine the total emissions for 
the Missouri portion of the KCMA. 

A comparison of the Missouri onroad mobile sources emissions for 2002 versus 2014 
show a large decrease in VOC and NOx emissions. These large reductions can be traced to the 
federal control measures that are being enacted between 2002 and 2014. Appendix P3 provides a 
table of the onroad emissions for the Missouri portion of the KCMA. The onroad emissions data 
for the Kansas portion of the KCMA can be found in Appendix P4. 

5.2.4 Offroad Mobile Source Emissions 

5.2.4.1 Offroad Mobile Source Emissions Description 

Offroad mobile sources are mobile and portable I/C powered equipment not generally 
licensed or certified for highway use. Offroad engines are classified according to distinct offroad 
equipment categories. These categories range from small lawn and garden equipment to heavy- 
duty construction equipment, large aircraft and diesel locomotives. 

5.2.4.2 Offroad Mobile Source Emissions Calculations 

The department's Air Pollution Control Program calculated the majority of the offroad 
emissions using the EPA's NONROAD2005 Model. This model provides the emissions for all 
offroad source categories except aircraft, commercial marine vessel, and railroad locomotive. 



39 



For the 2002 ozone season day run, most settings were left as default. The maximum, minimum 
and average summer temperatures were changed, and the gasoline fuel RVP was set to 7.0 psi. 
For the 2014 projected ozone season day run, these variables were changed, as was the sulfur 
content for diesel fuel. By 2014, Ultra Low Sulfur Diesel will be required for all offroad use 
except locomotive and marine. Appendix Ql provides all of the settings that were changed from 
the default values for the NONROAD2005 runs. 

The emissions calculations for aircraft, commercial marine vessels, and railroad 
locomotives were calculated from the SMOKE/IDA formatted file prepared by Pechan. The 
SMOKE model was used to calculate the typical ozone day emissions from these sources for 
2002. The 2014 projected emissions were determined by using the EPA's EGAS v5.0 software. 
EGAS v5.0 allows the user to set the base year of the known emissions. The future year is then 
chosen and EGAS calculates the growth factor based on SCC and county codes for all emissions 
sources. The following equation can then be used to determine the 2014 emissions levels from 
aircraft, commercial marine vessels, and railroad locomotives: 

2014 OSD emissions = 2002 OSD emissions x 2014 growth factor 
These emissions were then incorporated into the offroad emissions tables. 

A comparison of the 2002 and 2014 offroad emissions show a large reduction in both 
VOCs and NOx emissions. These reductions are the result of Federal control measure that have 
become effective since the base inventory year of 2002. Appendix Q2 provides a table of the 
offroad emissions from Missouri counties in the KCMA. The offroad emissions for the Kansas 
KCMA counties' emissions can be found in Appendix Q3. 

5.3 Biogenic Emissions 

5.3.1 Biogenic Emissions Description 

Biogenic sources are biological sources of ozone precursor emissions such as trees, 
agricultural crops, or microbial activity in soils or water. The EPA's Emissions Inventory 
Guidance for Implementation of Ozone and Particulate Matter National Ambient Air Quality 
Standards (NAAQS) and Regional Haze Regulations (August 2005) encourages the use of 
biogenic estimates for the NEI as the basis for SIP and Maintenance Plan inventories. The 
county-level biogenic emissions estimates summarized in the KCMA base and projected year 



40 



inventories were obtained from the 2002 NEI inventory from the EPA's ftp site: 
ftp://ftp.epa.gov/EmisInventory/2002finalnei/biogenic sector data/ 
5.3.2 Biogenic Emissions Calculations 

The EPA prepared the biogenic emissions using the BEIS3.12 model via the SMOKE 
modeling system. The BEIS3.12 inputs were based on 2001 annual meteorology and the BELD3 
land use data. The county-total emissions from SMOKE were estimated based on the "land 
area" spatial surrogate. 

The biogenic emissions data for a typical ozone season day were determined by summing 
the emissions for the months of June, July and August for each county, and dividing the county's 
three month total by 92 days. The result is the biogenic emissions for a typical ozone season 
day. It was assumed that the biogenic emissions for 2002 and 2014 would be similar. Appendix 
Rl and R2 respectively provide tables for the biogenic emissions of the Missouri and Kansas 
portions of the KCMA. 

5.4 Maintenance Demonstration 

The 2002 total anthropogenic emissions for the total KCMA are 226.42 tons/OSD of 
VOCs and 316.09 tons/OSD of NOx. The projected 2014 anthropogenic emissions for the 
KCMA are 181.07 tons/OSD of VOCs and 180.08 tons/OSD of NOx. Appendix S provides 
tables by source type for the anthropogenic emissions of the Missouri portion of the KCMA, the 
Kansas portion of the KCMA and the combined total anthropogenic emissions for the entire 
KCMA. Currently the KCMA is in attainment for the 8-hour ozone standard. Based on the 
emissions reductions of ozone precursors as a result of upcoming federal rulemakings already in 
place, the projections of this maintenance plan demonstrate that the area will remain in 
attainment for the 8-hour standard over the required 10-year time period. It is important to note 
that the formation of ozone is dependent on a number of variables that cannot be estimated by 
emission growth and reduction calculations. These variables include weather and the transport 
of ozone forming compounds from outside of the maintenance area. 

5.5 Verification of Continued Attainment 



41 



Recognizing the importance of maintaining current, valid emissions information, the 
department's Air Pollution Control Program agrees to update the emissions inventory for the 
KCMA Ozone Maintenance Area approximately every three years. The years of 2005, 2008 and 
201 1 were chosen as interim years. This emissions inventory update will include point, area, 
onroad and offroad emissions. Information from these future updates of the emissions 
inventories will be compared with projected growth estimations of the 2002 base inventory data 
to assure that the standard is maintained. The grown emissions estimates for the 2005, 2008 and 
201 1 interim years are included in Appendix T. 

6.0 CONTINGENCY PLANNING 

6.1 Purpose of Contingency Planning 

Section 1 10(a)(1) of the CAA requires the state to develop a contingency plan that, at 
minimum, will ensure that any violation of the 8-hour ozone standard is promptly corrected. 
Contingency measures may also be implemented in response to increases in VOC or NOx 
emissions that threaten to exceed the standard. The purpose of these controls in an attainment 
area is to achieve sufficient VOC and/or NOx emission reductions to eliminate further ozone 
violations. Implementing controls in response to ozone violations in attainment areas can occur 
without federal redesignation of the area to nonattainment. 

The department's Air Pollution Control Program collected information based on 
discussions and information gathered from industry, metropolitan planning organizations, the 
EPA and other states regarding the magnitude of VOC and NOx emissions reductions from 
various emission control strategies. The effectiveness and viability of possible control measures 
were compared. Some control measures interact with other potential control measures, thereby 
decreasing the overall effectiveness of the emission reductions. Estimates of the emission 
reductions expected from implementation of mobile source measures have been obtained from 
MOBILE 6.2 model estimates where applicable. The major considerations that went into 
choosing contingency control measures were: 

• cost effectiveness 

• easily realized reductions with minimal lead in time 



42 



• overall benefit of controls 

To assure that the area remains in attainment with respect to the 8-hour standard, additional 
control measures may need to be implemented in response to future violations of the 8-hour 
standard. The purpose of the contingency measure section in this maintenance plan is to 
establish a formal process that the department's Air Pollution Control Program would use to 
implement control measures in the event of a future violation of the 8-hour ozone standard. 

6.2 Contingency Measures 

When selecting control measures to implement in the event of a violation of the 8-hour 
ozone standard, it is important to consider the implementation time frame. A contingency plan 
needs to contain control measures that can be implemented in a relatively short time frame and 
demonstrate results quickly. Other control measures that may have a longer implementation time 
frame should also be considered for use based on their level of reductions. 

The ability of the KCMA to continue meeting the 8-hour ozone standard is dependent on 
both local meteorological conditions and the levels of VOC and NOx emissions in the area. As 
required by Section 1 10(a)(1) of the CAA, the department's Air Pollution Control Program has 
developed the following triggers and contingency control measures. The contingency control 
measures are designed as a two phased approach, with implementation occurring when the 
trigger of a specific phase occurs. 

Phase I would be implemented as the result of a violation of the 8-hour ozone standard. 
As previously discussed, a violation of the 8-hour ozone standard occurs when the area's design 
value exceeds 0.085 ppm. The design value for the area is determined by the average of the 
three-year consecutive years of fourth highest values calculated at each monitor. The monitor in 
the area that has the highest three-year fourth highest average value is the area's design value. 

The violation of the 8-hour standard, once quality assured, would trigger the following 
Phase I control measures to be implemented in the Missouri portion of the KCMA: 

• Early implementation of control devices on CAIR affected coal fired EGUs 

• Idle reduction regulation 

CAIR affected sources in the KCMA are expected to decrease their emissions substantially as a 
result of the first stage of CAIR. Under CAIR the state of Missouri developed budget allocations 



43 



for each EGU affected by the regulation. Based on the budgeted allocations in 10 CSR 10-6.364 
Clean Air Interstate Rule Seasonal NOx Trading, Table 1 compared to the 2005 reported NOx 
emissions from the affected EGUs in the KCMA, these reductions will reduce EGU NOx 
emissions in the Missouri portion of the KCMA by approximately 25% from the reported 2005 
NOx emissions. 

In addition to the Phase I control measures, it is anticipated that the voluntary measures 
included in the CAAP will continue to be implemented. It is also expected that in the event of a 
violation of the 8-hour ozone standard, the department's Air Pollution Control Program would 
submit a request to the Governor of Missouri to exempt the KCMA from the statewide ten 
percent ethanol mandate. The EPA's desired timeline for adoption and implementation of 
control measures is as expeditious as practicable, but no longer than 24 months. It is anticipated 
that all of these control measures can meet the desired timeframe. 

Phase II of the contingency plan would be triggered by the occurrence of either of the 
following two events. The first trigger would be the three-year design value for the area 
equaling or exceeding 0.089 ppm. This triggering event would become active one year 
following the end of the ozone season that triggered the Phase I contingency measure. The 
second triggering event would be three consecutive years following the Phase I trigger year with 
a design value greater than 0.084 ppm. Either of these events would implement the selection of 
control measures of Phase II. Following the implementation of Phase I, if any one year has a 
three-year design value equaling or exceeding 0.085 ppm, an evaluation to determine appropriate 
action will be undertaken by the department' s Air Pollution Control Program. 

The purpose of delaying the potential to implement Phase II control measures for a period 
of time following the implementation of Phase I is to allow for Phase I controls to be 
implemented and have an effect on air quality in the region before Phase II is implemented. It 
also allows for further evaluation of the various control measures that could be implemented 
under Phase II. Unlike Phase I where all control measures proposed will be implemented, 
further study of Phase II controls will result in the implementation of those that provide the 
greatest cost effectiveness and greatest benefits to the air quality of the KCMA to be 
implemented. Control options being considered for the Missouri portion of the KCMA for Phase 
II include: 



44 



• NOx reductions to coal fired EGUs not covered under CAIR that exceed 100 tons of 
NOx emissions per year 

• NOx reductions to industrial boilers and process heaters that exceed 100 tons of NOx 
emissions per year, 

• NOx reductions to cement kilns that exceed 100 tons of NOx emissions per year 

• Lowering the threshold for major sources of VOCs to 75 tons per year 

• Enacting regulations to reduce VOC emissions from 46 Architectural and Industrial 
Maintenance Coatings, including traffic coatings 

• Enacting emissions offsets of 1 . 1 : 1 .0 for new sources 

• Diesel Engine Chip Re-flashing regulation 

• Enacting a gas cap testing program 

• Eliminating the 1.0 psi waiver for fuel containing ethanol during the ozone season 
As previously mentioned, control measures will be selected from the above list based on 
emission reduction benefits, cost effectiveness and timeframe of implementation. In order to aid 
in determining the most beneficial control measures, photochemical modeling will be used as a 
tool for evaluation. The state of Missouri also reserves the right to consider additional potential 
contingency control measures if other beneficial emission reduction methods are determined to 
be useful to the air quality in the KCMA in the future. Adoption and implementation of controls 
shall take place no later than 18-24 months after the department's Air Pollution Control Program 
makes a determination, based on quality-assured ambient data, that a trigger established by this 
plan has been exceeded. 

Adoption of additional control measures is subject to necessary administrative and legal 
processes. The department's Air Pollution Control Program will solicit input from interested 
parties and affected persons in the KCMA prior to selecting appropriate contingency measures. 
No contingency measures will be implemented without providing the opportunity for full public 
participation. This process will include publication of notices, an opportunity for public hearing, 
and other measures required by the department's Air Pollution Control Program regulations. 

7.0 CONFORMITY 



45 



7.1 Purpose of Conformity 



Conformity analysis is a demonstration that the regional emissions from proposed 
transportation projects would not exceed the motor vehicle emissions budgets. If the conformity 
requirements cannot be met, then only certain types of project may proceed until the 
requirements can be met. The emissions inventory provides a basis for establishing new motor 
vehicle budgets, which are used to demonstrate consistency between the region's air quality 
goals and emissions expected from implementation of transportation plans and programs. 

7.2 Conformity Requirement 

The KCMA was required to perform transportation conformity after violating the one- 
hour standard. The CAA, Section 176(c) and regulations under 40 CFR part 51 subpart W, 
continued this requirement for areas that were designated as maintenance areas for any criteria 
pollutant or standard for which there is a NAAQS. Therefore, the EPA determined that once the 
one-hour ozone standard was revoked, areas that were designated attainment under the 8-hour 
standard would no longer be required to perform transportation conformity. The KCMA meets 
this determination. Therefore, conformity has not been required in the KCMA since 2004. 



46 



8.0 REFERENCE INFORMATION 

8.1 List of References 

1 CENRAP Emissions Inventory 2002, www.cenrap.org 

2 Economic Growth Analysis System (EGAS) v4.0, U.S. Environmental Protection 
Agency, http://www.epa.gov/ttn/chief/emch/proiection/index.html . 

3 EPA NEI BEIS3 . 1 2 by County and Month 
ftp://ftp.epa.gov/EmisInventory/2002finalnei/biogenic_sector_data/ 

4 I-Steps Point Source Database, Kansas Department of Health and Environment; Bureau 
of Air and Radiation, Topeka, KS, 2002 

5 Missouri Emissions Inventory System (MoEIS), Missouri Department of Natural 
Resources, Air Pollution Control Program, Jefferson City, MO, 2002 



47 



8.2 List of Acronyms and Abbreviations 



AQF 


Air Quality Forum 


AQS 


Air Oualitv Svstem 

X 111 ^1 111 1 I J K-J J iJ l^lll 


AQWG 


Air Oualitv Workins? Groun 

x 111 utiii l. y it v y i iviiit v — * i v j ka. yj 


CAA 


Clean Air Act 


CAAA 


Clean Air Act Amendments of 1 990 

V^lVLill X 111 X L w X. X llllwllvllllwllLJ V 7 1 1 .S .S \J 


CAAP 


Clean Air Action Plan 

V^-' J. Cll 1 X 1.11 X V V_ L1W11 1 J. CXI 1 


CAIR 


Clean Air Interstate Rule 


CE 


control efficiency 


CENRAP 


Central Regional Air Planning Association 


CERR 


Consolidated Emissions Renortins? Rule 

v^wiilj wiiviti ivu .1 — ;iiii iJ jiwii j ivw yj v / 1 liiic iv ^11 v 


CFR 


Code of Federal Regulations 


CHIEF 


Clearinghouse for Inventories and Emissions Factors 


CO 


carbon monoxide 


EGAS 


Economic Growth Analysis System 


EGU 


electric generating unit 


EIQ 


Emissions Inventory Questionnaires 


EPA 


United States Environmental Protection Agency 


FHA 


Federal Highway Administration 


VM 


vehicle insnection and maintenance nros?ram 

v v i 1 1 v i v_ iiilj I- / \s \^ liwii Liiivi iiiiiiiitwiiuiiw r-^ <^ w-iii 


IC 


internal combustion 

llltVl 11LL1 vV/lllL/ iJ L1W11 


IDA 


Inventory Data Analyzer 


KCI 


Kansas City International Airport 


KCMA 


Kansas City Maintenance Area 


KDHE 


Kansas Denartment of Health and the Environment 

IVilllkKli.' IW UUl L111V11L V/ 1 llVtllLll LillVi L11V A — ill T 11 v/lllllwlll 


LRTP 


Long Range Transportation Plan 


MACC 


Missouri Air Conservation Commission 


MARC 


Mid America Regional Council 

1 J 11U X 1111V1 IVU IVVClWllLil V J UllVll 


MSA 


Metropolitan Statistical Area 


NAAQS 


National Ambient Air Quality Standard 


NEI 


National Emissions Inventory 


NOx 


nitrosen oxides 

111 1,1 WCwll W/VlVlW LJ 


ORVR 


Onboard Refueling Vapor Recovery 


OSD 


ozone season day 


Pechan 


E.H. Pechan & Associates, Inc. 


nnb 


parts per billion 


nnm 


parts per million 


psi 


pounds per square inch 


RE 


rule effectiveness 


RFG 


reformulated gasoline 


RP 


rule penetration 


RVP 


Reid vapor pressure 


sec 


Source Classification Code 


SIC 


Standard Industrial Code 


SIP 


state implementation plan 



48 



SMOKE Sparse Matrix Operator Kernel Emissions 

TCM transportation control measures 

tpd tons per day 

ULSD Ultra Low Sulfur Diesel 

VMT vehicle miles traveled 

VOC volatile organic compounds 



49 



8.3 List of Appendices 

Appendix A 



Appendix B 

Appendix C 
Appendix D 
Appendix E 
Appendix F 
Appendix G 
Appendix Gl 

Appendix G2 

Appendix G3 

Appendix H 
Appendix I 
Appendix J 
Appendix K 

Appendix L 
Appendix LI 

Appendix L2 

Appendix L3 

Appendix L4 

Appendix M 



Map of the Kansas City Ozone Maintenance Area and 
Surrounding Area 

March 29, 2007 Public Hearing Notice and Certification of 
Publication of the Notice 

March 29, 2007 Public Hearing Comments and Responses 
MACC Adoption Certification 

Current State Regulations that apply only to the KCMA 
Clean Air Action Plan 
KCMA Monitor Information 

Map of the Air Quality Monitor Locations in the KCMA and 
the Surrounding Area 

Four Highest Exceedance Values and Total Number of 

Exceedances Annually at KCMA Monitors 

Total Number of 8-hour Ozone Standard Exceedances 

Recorded Each Year Since 1997 at all Monitoring Locations 

8 -Hour Ozone Standard Design Values for the KCMA 

Consolidation of Emissions Inventories 

Refinement of CENRAP's 2002 Emissions Inventories 

Calculation of Point, Area, and Offroad Mobile Source Ozone 

Season Weekday Emissions 

Point Source Emissions Inventory Information 

Missouri's Portion of the KCMA Point Source Typical OSD 

Emissions Data by SIC Categories 

Missouri's Portion of the KCMA Point Source Typical OSD 

Emissions Data by Individual Companies 

Missouri's Portion of the KCMA EGU Typical OSD Emissions 

Data 

Kansas' Portion of the KCMA Point Source Emissions Data by 
SIC Categories 

Missouri Statewide Estimates for the 2002 NEI: Area Sources 



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Appendix N 



Appendix O 
Appendix 01 

Appendix 02 

Appendix P 
Appendix PI 
Appendix P2 
Appendix P3 

Appendix P4 

Appendix Q 
Appendix Ql 
Appendix Q2 

Appendix Q3 

Appendix R 
Appendix Rl 
Appendix R2 

Appendix S 
Appendix S 1 

Appendix S2 

Appendix S3 



Research and Development of Planned Burning Emission 
Inventories for the Central State Regional Air Planning 
Association 

Area Source Emissions Inventory Information 

Missouri's Portion of the KCMA Area Source Typical OSD 

Emissions Data by Source Category 

Kansas' Portion of the KCMA Area Source Typical OSD 

Emissions Data by Source Category 

Onroad Mobile Source Emissions Inventory Information 

Onroad MOBILE Model Settings 

Onroad VMT Data by County 

Missouri's Portion of the KCMA Onroad Mobile Source 
Emissions Data by County 

Kansas' Portion of the KCMA Onroad Mobile Source 
Emissions Data by County 

Offroad Mobile Source Emissions Inventory Information 

Offroad NONROAD2005 Model Settings 

Missouri's Portion of the KCMA Offroad Mobile Source 

Emissions Data by Source Category 

Kansas' Portion of the KCMA Offroad Mobile Source 

Emissions Data by Source Category 

Biogenic Emissions Inventory Information 

Missouri Biogenic Emissions Data by County 

Kansas Biogenic Emissions Data by County 

Summary Anthropogenic Emissions Inventory Information 

Missouri's Portion of the KCMA Anthropogenic Emissions by 

Source Type 

Kansas' Portion of the KCMA Anthropogenic Emissions by 
Source Type 

Total KCMA Anthropogenic Emissions by Source Type 



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Appendix T Anthropogenic Emissions Inventory for Interim Years 2005, 

2008 and 2011 

Appendix Tl Anthropogenic Emissions Inventory for 2005 

Appendix T2 Anthropogenic Emissions Inventory for 2008 

Appendix T3 Anthropogenic Emissions Inventory for 201 1 



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